AUDITS & REVIEWS OF SCHOOL BASED SERVICES T I M K U B U K A B E E R S I N G H

AUDITS & REVIEWS OF SCHOOL BASED SERVICES T I M K U B U K A B E E R S I N G H

INTRODUCTIONS Tim Kubu, Manager MDHHS Bureau of Audit, Audit Division, Audit & Review Section 13 Years with State of MI Kabeer Singh, Auditor Started with the State in February, 2018 December, 2017 college graduate

TOPICS Schools & Medicaid The Audit Process Different Financial Reports Public Accounting Manual Types of Audits Single Audit Office of Inspector General (OIG) Intro to the OIG Recent OIG Audits MDHHS Audits and Common Findings IEP Requirements

SCHOOLS & MEDICAID Direct Medical Services Related to MAER cost report Ex: Speech Therapy, Occupational Therapy, Nursing Services

SCHOOLS & MEDICAID Administrative Outreach Program On the quarterly financials Administrative Costs

REMEMBER - MEDICAL To be covered by Medicaid, service must address a beneficiary s medical need that affects his/her ability MDHHS does not reimburse for therapies that do not have medically related goals

REFERENCE MATERIAL

AUDIT PROCESS Planning Phase Audit Fieldwork Phase Report Preparation Phase

PLANNING PHASE Sets the foundation for the audit process Typical activities include: Conduct the audit entrance meeting Develop scope and objectives Develop audit plan Perform risk assessment Select items to be audited

PLANNING PHASE - RISK ASSESSMENT Single Audit findings, deficiencies MAER Medical Staff Costs Quarterly Financials 4094/4096

PLANNING PHASE RA RANKING Low, Medium, High Dollar amounts and internal control issues Develop ranking scale Assess ISD and LEA s based on criteria

AUDIT FIELDWORK PHASE Driven by scope, objectives, and other agreements set forth during planning Formal Testing Financial report accuracy Funding source identification Claims validity Preliminary Findings

REPORT PREPARATION PHASE Typical activities include: Submit preliminary report Conduct internal quality assurance process Obtain preliminary response Conduct exit meeting Finalize report

FINANCIAL REPORTS: SE-4096 Special Education Actual Cost Reports Required for State Aid purposes Records all amounts to the nearest dollar for the YEAR

FINANCIAL REPORTS: SE-4094 Transportation Expenditures Records all amounts to the nearest dollar

FINANCIAL REPORT: SE-4107 School Bus Inventory Report Required by districts using black and yellow vehicles Updated Annually Required to complete before 4094

FINANCIAL REPORTS: MAER MEDICAL STAFF Costs related to the direct medical service staff (OT, PT, RN, etc.) MAER Medical Staff Cost Report is completed on the accrual basis The interim monthly payments are based on prior year actual costs and reconciled on an annual basis to the current year costs.

PUBLIC ACCOUNTING MANUAL Mandatory guide for classifying accounting transactions Generally in conformity with GAAP, GASB, and state regulations

CODING STRUCTURE

FUNCTION & OBJECT CODES

PROGRAM & GRANT CODES

USE OF ESTIMATES The financial data reported must be based on actual expenditures Generally Accepted Governmental Accounting Standards (GAGAS)

SE-4096 VS MAER The MAER should be a subset of the costs reported on SE-4096/4094 because you are only including allowable participants from Time Study Rosters and allowable medically related costs within certain object codes

TYPES OF AUDITS Single Audits OIG Audits MDHHS Audits

SINGLE AUDIT For non-federal entities that receive greater than $750,000 of federal assistance Generally done annually Provides the Federal government Reasonable assurances Encompasses both Financial and Compliance components

SINGLE AUDIT (CONT) The Single Audit determines: Financial Statement Compliance Federal Program Compliance Internal Control Compliance

SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS

SCHEDULE OF FINDINGS & QUESTIONED COSTS

OIG AUDITS - HHS OFFICE OF INSPECTOR GENERAL Largest Inspector Generals Office of the Federal Government Conducts audit to investigate misuse of the Medicaid Program Aimed to help promote overall efficiency of HHS resources

RECENT OIG AUDITS Michigan- as it related to RMTS (Sep. 2016) $954,000 in Federal Funding New Jersey- payment rates for School Based Services (Nov. 2017) $300 million in unallowable costs $306 million in unsupported costs

MDHHS AUDITS The State of Michigan SBS Audit section is responsible for conducting external compliance audits of Intermediate School Districts funded by MDHHS. Two main objectives: Assess Internal Control over SBS Medicaid based claims. Assess compliance with Federal and State laws and regulations.

COMMON FINDINGS OF MDHHS AUDITS - QUARTERLY FINANCIALS Federal Funds Inclusion of Unallowable Expenditures Lack of Oversight of Financial Data Reported

COMMON FINDINGS OF MDHHS AUDITS - MAER Staff Pool Listing Errors Inclusion of Unallowable Expenditures Wrong Lines & Columns

COMMON FINDINGS MAER - TRANSPORTATION Lack of Oversight of Financial Data Reported Calculation Errors Overstatement/Understatement Wrong Line/Column

UNALLOWABLE: TUITION Tuition Reimbursement (2310) These costs coded under object code 2310 for employees to return to higher education to complete degree requirements are not reimbursable as a necessary cost of special education under state school aid.

COMMON FINDINGS OF MDHHS AUDITS - STUDENT CLAIMS Attendance Missing Documentation Provider Notes

IEP REQUIREMENTS Prescription: Occupational Therapy, Orientation & Mobility Services, Physical Therapy Prescribed by a physician and updated annually Referral: Speech, Language & Hearing Therapy Referred by a physician and updated annually Authorization: Personal Care Services Authorized by a physician or other licensed practitioner and updated annually Written Order: Nursing Services Direct service interventions require a physician s written order when the initial need for services is determined

IEP REQUIREMENTS CONTINUED The treatment plan must be signed, titled and dated by the qualified staff prior to billing Medicaid for services and must be retained in the beneficiary s school clinical record.

IEP REQUIREMENTS CONTINUED Must be maintained by the provider of the special education transportation. Ridership must be documented for each one-way trip.

QUESTIONS

CONTACT INFORMATION Tim Kubu Email: KubuT@Michigan.gov Phone: (517) 241-9163 Kabeer Singh Email: SinghK2@Michigan.gov Phone: (517) 335-4792